Prosecution of foreign bribery by the U.S. has increased in the last several years but the government has not consulted the private sector often enough as it reviews its policies, the OECD Working Group on Bribery said in a new report (pdf) that constitutes the final phase of a peer review.

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Since 2002, 71 individuals and 88 companies have been held criminally or civilly liable for foreign bribery by U.S. law enforcement, and during that time the U.S. rapidly increased the size of fines it collected from offenders. In the report, The Organization for Economic Cooperation and Development praised relevant legislation passed since the last review, which took place in October 2002 (pdf), including new accounting standards in the Sarbanes-Oxley Act of 2002 and the whistleblower provisions of the Dodd-Frank financial regulation reform law.

The Working Group also highlighted the creation of enforcement units specifically devoted to handling bribery cases, regulators’ use of non-prosecution agreements and deferred-prosecution agreements to get cooperation from companies, and the companies themselves agreeing to the appointment of corporate monitors.

“Vigorous enforcement and record penalties, alongside increased private sector engagement, has encouraged the establishment of robust compliance programs and measures, particularly in large companies, which are verified by the accounting and auditing profession and monitored by senior management,” the report said. Creating effective compliance programs at small and medium-size companies poses a problem for all 38 parties to the OECD convention on bribery, including the U.S., the report said.

However, there are still places in which the U.S. could improve, according to the report. The OECD said that the U.S. should consider the views of the private sector and of civil society groups in its review of policies on facilitation payments, which the group has previously called “corrosive,” pushing for an outright ban on them.

The group also said regulators should make plea agreements, non-prosecution agreements and deferred-prosecution agreements publicly available “where appropriate” and to make sure that the statute of limitations is appropriate enough that it allows for proper investigation and prosecution.

U.S. regulators welcomed the positive review. “Bribing foreign government officials is not a legitimate way to do business. The United States has risen to the forefront of enhanced global efforts to combat foreign bribery, including through our vigorous enforcement of the FCPA,” said Lanny Breuer, an assistant attorney general in the Criminal Division of the Justice Department.

The U.S. will make a follow-up report to the OECD in a year on its implementation of the group’s recommendations.

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